. Ale

[Effective Date: 10/24/2003 [Revision No. 00 [Document No. ORAUT-TKBS-0005 [Page 25 of 1225 J

5.0

As AEC (196Ga) observed, no radiaflon measurements or evaluations of dust exposure ware made in
the Mallinckrodt plants in the first few years of operations because it was expected that the processing
of uranium ores and compounds would invalve little risk of radiation injury; this was because of the

bearing pitchblende ores), they determined thera to be “considerable” (AEC 1950a). NYOO and
Mallinckrodt began a program of workplace and personne! monitoring.

AEC and Meliinckrodt had already begun to issue fim badges in 1946 (AEC 1950a), with apparently a

stnall-scale effort begun in late 1945. To this was added breath radon determinations in 1946 anda

hee oe reriamaal su program in 1948 (AEC 1950a). Urinalysis measurements appear to have
also.

‘Since litte individual monitoring data Is avaltable prior to about 1946, some extrapolation of existing
data fo cover the unmonitored periods Is necessary, a8 AEC itself tried to do (AEC 19502). Also, data
must be analyzed'te allow missing dose to be calculated for individual workers where there are gaps
in the monitored petiod. The sections below provide information as to the available data and other
information that will allow this to be done.

AEC thought that as a resutt of improvements planned for 1949 and early 1950, there would be no
whole-body radiation exposures greater than 300 mrep/wesk in Plant 6 and the dust concentrations
would be reducad to the AEC's “preferred level" of 50 ugim®, or 70 dpmim® (AEC 1949). AEC was
also expected that construction of a new metal plant (Plant 6E), in which UF, would be reduced to
metal es was currently done at Plent 4, would produce satisfactory occupational) enacennen
conditions (AEC 1949). It was also expected that in 1951, the new UOz-to-UF, {Plant 7) would
further reduce exposures (AEC 1949)... However, with the incraase Ip. pr these

not met in all cases, although there were some succassas and ‘
the airbome and extemal exposure levels, as shown in the text and tables below.

5.1 UNITS, LIMITS, AND RECOMMENDATIONS

‘The exposure (dose) units used by MED/AEC during most of the relevant period were mi
(mR) for gamma doses and milllirep for beta doses; the abbreviations in the film badge and other
records were mr and mrep respectively. The rep is equal to.0.93 rad.

During the war, AEC's recommended (“tolerance”) levels of extemal exposure for the uranium
processing were 700 mR per week ti the whole body and 3500 mrep per week to the hands
(AEG 1949; AEC 1950b); AEC (1950b) stated that this was 700 mrep per week “each of beta and
gamma’, as accepted by the University of Rochester in processing film badges (i.e., Rochester did not
flag reported as above tolerance if the weekly beta and gamnta doses were each below 700
mrep). ‘At some point, when NYOO had assumed the job of reading the film badges, the tolerance
jevel was lowered to 500 mrep per week, which Mallinckrodt continued to interpret as applying to
either beta or gamma but not fo the total (AEC 1950b). However, Mallinckrodt used a control level of
150 mrep per week, cailed the "preferred level" in its 1946-1952 film batige records. The number that
was compared to this lave! was the sum of the gamma dose in mR (Le., mr in the records) and the
beta dose in mrep, as registered by the film badge, apparently with no adjustment of the mrep by the



c

»

é

ape a ea . wat .
4 a Hovever, & zero value used to reflect Eo Data. is grossly mislead-

aD ing, particularly if there was sufficient exposure to have caused”

J

a positive UW value if. a sample had been tested Gee above). : S

* 3 There was no film badging ental ‘1986, “apa thea. _oaly in the .
Plant 6 vadinuin areas ‘until 1948, when plant wide film. badging was” .

started, Again: A .000 value to reflect No. ‘Data is obviously mis—

leading. (see 1 above). : se a
* Al A very few breath radon samples were taken and - tested begin~

ning in 196, mone before. ‘he comprehensive BR progran aia not

get underway until 1948 and ended for all practical purposes in :

1957. Here again the use of .000 for Yo Data can be highly mis-

ieading (see 1 above). . .

Several names were tested by the simple process af checking
the termination date. : IZ ternination was before 1946, there

should be no exposure data in the CTC records. If termination was

between 1946 and 1948, there could orly be film badge data (Exter~ -

nal Exposure) or BR data in the HCW files, although the University
of Rochester representatives did conduct some sampling of the pop-
ulation.

Some of the set narked "Non Exposed Zmployees of Recora” were
checked against original Health Departzent records; some of the ;

more severely dust exnosed employees were included in this group...

The raw data néeded to correctly reflect a Destrehan employee's
exposure awaits key punching and entry to CTO files. It was sorted in
1973 but not purched. The recent zovezent of files nas contributed te
some disorganization of that raw data wie. has been reorganized. Pro+

gramnzer tine has been made available te sors out che interlocking gro~

- gtans for tring ail of the raw data together. This is a diffitnit

-problen due to tre facts tnat various data nay be recorded in the iow

B


Table of Contents

Letter to the Honorable Tommy G. Thompson
Special Exposure Cohort Petition
"Petit

_ Pott
; Petitioner

Site Profile Documents

Al Estimating Dose, Unmonitored Period: Workers without Subsequent Dose Monitoring Records
A2 Estimating Dose, Unmonitored Period: Workers with Subsequent Dose Monitoring Records
‘3 _ Information and Available Data Regarding Urinalyses

Documents Supporting SEC Petition

Ad Mallinckrodt Chemical Works (References urine and breath radon) (From private archive)
‘AS-1_ Urine Samples (Sept. 20, 1951) (From private archive)

‘A5-2. Techniques of Radon Breath Sampling (From private archive)

Site Profile Documents

AG Film Badge
AT BreathRadon

Documents Supporting SEC Petition :
AS’ Destruction of Records and Lost Medical Records (Thomas Mancuso)
Ad 1949 Dust Study: Conscious Coverup (Mont Mason)
‘10 Exposures More than Realized at Weldon Spring (From private archive)
All Spotty, Incomplete Records (University of Pitesburgh)
Al2_— Gaps in Present State of Knowledge (Per FOIA request via CD)
‘413 Mallinckrodt’s Uranium Operations for the U.S. Government: MED and AEC
(From private archive) .
Al4 1951 Memorandum from Merril Bisenbud: Cover Letter to A15 (Source: FOIA request)
Als ‘An Estimate of Cumulative Multiple Exposures to Radioactive Materials
(Hanson Blatz and Merril Eisenbud)
AI6 ‘Some Observations on Uranium Exposures within the Nuclear Industry (4. F. Becher)
‘Al7 _ Oral History of Merril Eisenbud (U.S. Dept. of Energy)

Site Profile Document
A18 States that workers worked 8 to 8.6 hours per week. (NIOSH)
Note: This is untmae, Mallinckrodt workers worked many seven-day weeks in 12-to 14-hour

shifts.


. Ap.

[Effective Dats: 102472003 | Revision No. 00 | Document No. ORAUT-1KBS-0008 ] Page 41 of 15 _]

exposure potential at various times due to process improvements, engineering modifications, or the
building of new plants, three periods were established for the determination from the cases of the

typical daily intake, as given in Table 31.

Table 31 does not include intakes for workers who processed wastes containing thorium (onium);
estimated annual intakes for these workers are given in Table 32. It appears that there were faw such
workers: (1) AEC (1955c) reports studying only six workers in thelr Plant 7E dust exposure study
whereas, @.g.,119 were studied in Plant 6E, (2) few worker cases were found in the large stripped
urinalysis file where it was clear that the worker did this type of work, and (3) the thorium worker in
every case that was found had worked in other areas where an intake of uranium material was.
possible, itis not clear that thorium itself in urine was measured at alt, rather than, say, gross

its daughters) and thorium. Hence in dese reconstruction the urinalysis data from mid-1955 on for
workers who processed thorium wastes should be generally be assumed to consist of whichever
source set (U-234, U-235, and daughters or Th-230) gives the more conservative result.

5.3.7

Breath radon measurements began to be made In 1947, but only for workers who worked in areas
where there was a potential for radiurn intake (AEC 1950a). Breath radon samples were sant to AEC-
NYOO for analysis; in 1955, AEC-NYOO was analyzing about 500 Mallinckrodt samples a year, taken
semiannually at a minimurn but about quarterly when permitted by AEC-NYOO sample capacity
(MCW 1955). Breath radon records are available in scattered form in reconstruction project files.

Breath radon samples were collected by obtaining one-fiter samples of exhaled breath after two days
of non-exposure, usually on a Monday moming (AEC 1950a); MCW 1950f). The samples were
measured .at NYOO by an. “automatically recording puise-counting devica” (AEC. 1950a). In.early
1960 AEC apparently became concerned about the high background that seemed to be present
where the samples were being taken (MCW 1950f). Mallinckrodt agreed to take test samples
elsewhere than in their usual testing area and also to take 2 room alr sample in thelr: normal testing

GEOB XADAZC nAEC jadged jr backround for a brea don
adjacent the change room, whith onabed wakes eee Vyshals afer a honor witout
: , h bled workers to tak pl a shower

AEC considered that many of the early breath radon samples likly represented transient as well as

fixed burden and that the background level at the point of sampling (which was generally ignored) was
likely to have been relatively high; thus the resulting estimates thay made of alpha radiation to tha
bone based on breath radon measurements would typically be higher than was actually the case
(AEG 1950a). Up to about.1950, AEC assumed that 1 BCH. of sample after at least two days of non-
exposure represented a fotal radium burden in bone of approximately 0.2 ug of Ra; however, AEC
had then decided to use an RBE of 20 for alpha to bone marrow and a skeletal weight of 7 kg as
agreed on at the September 1949 Chalk River Conference, to give 1600 mremfweek to bone for each
0.1 ug Ra deposited (AEC 19502). -

Whole body and kung counts appear to have been performed rarely if at all, since workers had fo be
Sent to sites outside Missouri for this to be done or a mobile counter would have had fo be brought fo
St. Louis. Hence there were evidently so few such counts done as fo be of fittle use in reconstructing


.

| Eifeciive Date: 1omaa003 | Revision No. 00 | Document No. ORAUT-TKBS-0005 Page 43 of 125 _|

dumping, scooping, and scraping operations In which feed, UO2, UOs, UF, and dust were handled or
crucibles and fumaces were cleaned; the “plowing” (scraping) of the cenirifuges; and the scraping of
cake off the Feinc filter cloths {this was the pitchblende cake during the pitchblende years). Thus
significant external dose reduction usually followed any mechanization of these processes.

- Because the gamma dose arose mainly from the radium and its daughters, the gamma dose was
significant only in those areas where the source material had not yet had the radium separated; where
radium-bearing residues were present; or where uranium products were stored for long enough
periods of time that the daughters built up again. ‘This meant that the gamma doses tendad fo be
highest in Plant 2 and later in Plant 6 (AEC 1949), especially around cre drums and storage areas for
the radium-bearing residue, K-65. ‘Shielding had been designed into Plant 6 and more was added in
4848 in some areas {AEC 1949). As noted in Section 5.2 above, there was also up to.2.6 mCi of
radium built up in the residue that was processed in 1955-1957 fo concentrate thorlum, although this
twas clstiiuted in the 380 fons thet was processed Ino the 2800 gafons of soon sent to Mund
‘ables 4 and 6).

Doses registered on film badges wom by people not working directly with the U and equipment, such
as guards and office workers, was more likely from gamuna exposure than from beta exposure. This
is because they were usually at some distance away from the source (the uranium and its daughters).
It is true that the dust was found throughout the plant to varying extents, but that would likely not
contribute to the extemal dose rate much in or near bulidings where there was a substantial Ra
content in any uranium product or residue.

A 1958 AEC report on uranium mills gives 1.5 to 25 mrep/hr, with an average of 15.5 as the beta dose
tate at three feet from bulk ore concentrates (AEC 1958, Table Xi). AEC (1948a) gave the beta
contact dase rate with the (Ra-containing) Feine filtrate sludge (K-65) under equilibrium conditions as
over 500 mrem/hr; however, they stated, they had no way of knowing how close to equiliorum it was.
AEC estimated the dose to an operator's hands from removing lids from ore drums at 200-300
mfRiday, even after a proposed body shielding window was erected (AEC 1948b). .

Regarding experience at the Paducah site, Baker (1958) reported that the Th-234/Pa-234

YJ at equilibrium, producing 240 mrad/hr at the surface of U metal, 208 mradyhr at the surface of UO,
and 183 mrem/hr at the surface of UF,. Further, during UO, prep by “our suppliers” (0.9.
Mallinckrodt), much of the beta-active material was removed, but built back up to 50-100% by the time
it got to the UF production facilities (Baker 1958). This suggests that significant buildup could occur
time was likely less than a tew days. Efsenbud (1975) points out that 90% of equilibrium beta activity
Is restored by 90 days aitar vacuum casting. Eisenbud (1975) reports high dose rates, up to 1
rad/week to the body and even more fo the hands, from loading of UF; into UF reaction vessels.
This too implies that if enough time elapsed, UF, loaded at Mallinckrodt into the bombs could also
produce relatively high beta dose rates. Metallic uranium in equilibrium with Tht-234/Pa-234 could
produce up to 235 mrad/hr to the basal epithelium when the mata! was in contact with bare skin;
heavy gloves would significantly reduce this (Eisenbud 1975).

In addifion to the beta dose rate from the uranium as natura! uranium, uranium oxide, efc., there were
two waste concentrates that produced high beta dose rates. First, when ether was used with the
urany/ nitrate to extract the uranium, Th-224 and Pa-234 (also called UX1 and UX2 respectively) were
left in the aqueous phase (also called the aqueous uranium tails) (Elsenbud 1975). This aqueous
‘solution was filtered, resulting in a residue (cake) containing the beta emitters...


. Doe Breath Rodin CQ) _imneasneve ob

~~ . @ ® ESTABUSHED 1867 @ @ ; AS@)
MALLINCKRODT CHEMICAL WORK ,

MANUFACTURERS OF . -

igauLe ADDRESSES:
FINE CHEMICALS FOR MEDICINAL, PHOTOGRAPHIC : sas
ANALYTICAL AND INDUSTRIAL PURPOSES: mE ae
PAC IONE, FT. LOS HERSELF CITY, MOWERERL NE countrre ease
“5 sucns opnezar. comes wy smcne Comat GEVEEAND “paeieeaomee
Se BER ST. LOUIS.7. MO.
GS
a : january 8, 195%
1/6/52

He. W. 3B. Harris :
U. S. Atomic Energy Commiselon

Bew York Operati

oe eee TNE wea a ee —7 COW)

New York 23, New York
Subject: TEOHNIQUES OF RADON BREATH SAMPLING
Dear Bali:

You may remember our conversations of a few weeks ago concerning the
reliability of a set cf breath radon results, which were returned from your
laboratory with readings of 1.3 ¢o 1.4 < 10712 aurtes per liter, This matter
Was also discussed with John Harley. : :

tie have just received @ set of romite vhich were the re~checks
on these same individuals, Both sets of samples were taken by our old
technique without the respirators recently forniehed us by Mr, Harley,

“You will note that tae difference between the reported. breath samples _~
is of. the sam * 98 the difference in the room air concentration on
the day of the sample, @his is clearly indicated in able I.

TABLE ¥

COMPARISON OF BREAPH SAMPLES ARD “ROOM ATR" SAMPEES
{421 units 10-22 ¢/1)

Name_ Room air 0.8 Room Air 0,2
1.3 0.8
1s Lost
LM 0.6
Le - 0.7


AX

| [Eitective Date: 10/2472003 | RevisionNo. 00 | Document No. ORAUT-FKBS-0005 [Page 58 0f 125 |

73.23 Photons in the 75% AP/75% ROT Catagory

Exposure geometries for this category of workers reflects a 75% AP/25% ROT geometry, This
geometry is appropriate for many process workers.

7.3.2.4 Photons in the 90% AP/10% ROT Category (Process Workers)

Time-and-motion studies document that certain workers received most of their extemal exposure ina
short period of time performing dose-intensive activities. This geometry should be applied to process
workers In the higher-dose categories.

7.325 Photons: Non-Process Workers

‘These workers are expected to have entered process areas only incidentally and rarely approached
process equipment as part of their assigned duties. Examples of these types of workers are cierks,
other office workers,-and dispensary personnel.

73. Photon Eneray Ranges

Metal plant workers are exposed to natural uranium separated from redium and its progeny, the
source of high-energy photons in uranium ore. Workers in the refinery were exposed to uranium in
many states, from minimatly processed ore through the various stages of uranium separation. Other
workers, such as laboratory workers and guards, were exposed to uranium in varying states also.

Photon doses for all workers should be assumed to be evenly divided between the 30 -250 keV and
> 250 keV energy ranges.

74 RECONSTRUCTED EXTERNAL DOSE

Some considerations for the reconstruction of extemal dose in this technical basis document are
based on the methodology discussad in Watson et al. (1994): That study utilized external doses for
workers. @ Nations story (ORNL) and the Y-12 Facility in Oak Ridge, Tennessee
to evaluate the’ accuracy of estimates resutting from the use of the NEARBY procedure, developed by
D.J. Strom, as cited in the reférence. The procedure is not treated In detail here, due to the ready
availablity of the reference. The results are significant for this document, however. A statistical test
for goodness of fit between estimated doses and actual doses showed the first step (of the 10 ordered
steps) of tha NEARBY procedure to result in the smallest difference between estimated and actual
doses for ORNL. The correlation between estimated and actual dose went down, in general, with
increasing step, with exceptions. For the uranium facility, Y-12, the use of department median or
mean doses produced as good a fit as use of the NEARBY procedure. Though exact application of
the NEARBY procedure is. not possible in this case, the methodology is followed to the extent possible
with existing dose monitoring data, .

The tack of early extemal monitoring data for Mallinckrodt fikely refiecis the novelty of the uranium
processing industry, the provisional nature of early uranium activities at Mallinckrodt and the
assumption that airbome exposure was the primary hazard. The implementation of 2 more
comprehensive health and safety program in the early post-war period led to questions about extemal
doses that previously had gone unmeasured. This resulted in the pubfication of the AEC report “An


designated SECs.
Ina document, titled: “Mallinckrodts Uranium Operations For The U.S. Government: ”

MED and AEC" It states that several nndred workers during 1942-1952, are among the
most highly exposed workers in the entire history of the U.S. AEC program.

1n an oral history of Merril Eisenbud, Director of Health and Safety Lab in NLY..
conducted on January 26, 1995 by Thomas J. Fisher, Mr. Eisenbud states that many
Mallinckrodt workers were exposed to in excess of over 200 times the preferred levels of
exposure. He also commented that workers were excreting in excess of a miligran of
uranium per day in their urine.

Mallinckrodt workers also handled K-65 residue, Sperry Press Cake better known as
Airport Cake, their shudges and raffinates. At the St. Louis plant the workers were
exposed to Actini Protactinnum, Polonium, etc.. The Belgian Congo Pitchblend was 65
- 75% pure. The Weldon Spring workers were exposed to transuranics such as
Plutonium, Neptunium, etc., with like circumstances to the Paducah Gaseous Diffusion
Plant, which I understand, is also an original SEC. Workers from both MCW plants were
never monitored for any of these.

It is my understanding that in order to become part of the SEC, one must fit the following

(1) You mast show that the workers were endiiigered
(2) You taust show that NIOSH cannot dose reconstruct with sufficient accuracy.

Ubelieve that in the case of both Mallinckrodt facilities, I have proven both beyond a
shadow ofa doubt. ©

I greatly appreciate ail of the hard work that NIOSH has put forth in dose reconstructing

the claims that they have completed and that have been positively adjudicated. But the fact

remains in that, due to the loss and destruction of records, the altering or incompleteness
a . ing, of monitoring data. a8 ¥ Hl as 2

To summarize, Mallinckrodt workers were obviously endangered, they were never
monitored for all radionuctides and istopes. They were never told of hazards or given
Proper protective gear. And on occasion, were left in an area to conduct clinical
experiment on, without their knowledge or consent. They are known and documented to
be the most highly exposed population of workers in the history of the United States

Equity and parody demand that this class of workers be added to this special status.
‘These workers fit the very criteria as the other four sites that were in the original
legislation. Please do not let these Atomic Cold War Warriors contzibutions to our

country’s ongoing prosperity continue to go unrecognized. I implore you to add the


07-17-2004

SEC Petition

Office Of Compensation Analysis and Support
NIOSH

4676 Columbia Parkway, MS-C-47
Cincinnati, Oh 45226

Att Honorable Tommy G.
Secretary of Health and Human Services

Dear Sir:

Tunderstand that the procedures for the petition by HHS pursuant to 42 USC 7384 (q)
are now finalized and I would like to respectfiully submit a petition for Special Exposure
Cohort status for the employees of Mallinckrodt Chemical Works at the Destrehan, St.
Louis, Mo. facility from 1942 until 1957 and for the employees of the Weldon Spring,
Mo. facility from 1957 until 1967.

1am sending a hard copy binder as well as a faxed transcription of the petition.

There are three petitioners; myself, (UAW
and . _\(survivor).

I would like to add the following comments to this petition.:

By virtue of the site profile and documents to date, on the MCW, St. Louis site, there is
limited to no individual monitoring data for the time period of 1942 until 1948. Whatever
other data is available is questionable at best. And this also includes the data or lack of, for
the Weldon Spring site, in which, there has to date, not been 2 TBD completed.

Ihave attached numerous documents and statements that are indicitive of lost and
destroyed records, incorrect exposure documentation, as well as possible falsification of
records. Thave also enclosed documents regarding concious “coverup” by the vendor due
to liability concerns, discussion of false bench marks, even documents discussing using
these workers as “human radiation experiments".

Enclosed is documentation discussing there not being even one complete set of records for
the Weldon Spring Mallinckrodt employees, as wel as a report stating the exposures were
more than

Thave enclosed several documents to and from Dr. Thomas Mancuso regarding "spotty"
records, missing files,.even documentation that Mallinckrodt St. Louis records were more
“spotty” than those of Oakridge. Which, as I understand it, is one of the four already


~ te

;
fF .
ose eo. Tt

ur. We. B. Harvis - . Jamery 6, 1952
ee We -were informed some years ago ty the Bureau of Stendards that the
Foom sir concentration, as long as it wae in the same order of magnitude as

the breath sample, vas of Little importance in teking breath radon samples.
Evideitiy this information was incorrect, I telieve this set of data; although
the nonber of samples is not large, is @ dramatic demonstration of the point
which Mr. Harley has been trying to uake; that close control of the inhaled air
is necessary in order to Obtain valid and reprodncible breath radon rdsvltes.

” Very trmily yours,
- :
KMALLINCKRODE CHEMICAL WEKS

ee

KJCaplen

i reo Rasen (&) Liniortenes of reab


o wre : . Al

[Eiiective Date: 10242003] Revision No. 00] Document No. ORAUT-TKBS-0005 "| Page 60 of 125 J

142

it is assumed that workers without subsequent dose monitoring records elther terminated prior to the
- beginning of dose monitoring or performed work that did not meet tater Mallinckrodt criteria for

monitoring. For the fonner, 8 surrogate cose history is to be formulated based on workars with infor

job titles during the period of extemal radiation dose monitoring. The latter may have-had low- or no-

sioee fabs during the 1942-1946 urmontiored period, in which case assignment of a lower dose based
. on the median dose from the early monitored period is a claimant-favorabls measure.

Doses to these individuals should be assigned based on surrogate dose history esfimated
from recorded doses of co-workers from 1946, or the closest subsequent period. Dose
teconstructors must compare information available from the DOE record and the computer-
alded telephone Interview (CAT!) fo the reference documents in order to identify workers with
a similar work history, whose recorded doses should then be applied to the worker for whom
no doses were found. Care must be exercised to identify the appropriate work history fo use
Bs a surrogate for the subject employee, but adequate information is likely in the dlocusnent® 19
formulate a reasonably accurate surrogate dose history when the case file contains adequate
work history information for the employee.

For these individuals with no identified records, and work assignments subsequent to the
unmonitored periad that would probably not result in significant exposure, application of the . +

-fynangn, cones. foam. the. sary monknoad pation provides, a claimant claimant-favorable estimate that
ikely addresses any incidental dose that may have been receivad from 1942-1945, These are
presented in Table 36,

‘The valle i Table 36 were gariratad fom the averau doses received by Malnckrodt pitt plant”
workers. during the earliest known period of flim badge. manitoring, the 15-week program described
above (Rochester 1950). it incorporates significant uncertainty due fo the following isatures of the
data. Firstly, only total doses were listed for each worker for the number of weeks monitored (n= 1-"
18). Second, no detail is supplied in the raferenca as to. what activities the workers were engaged in,
other than. the fact that the location was Usted as “pilot plant.” The memo, however, states that the
floses are fom “prior to the operation of the current plant and fs dated around the time that Plant 6
became operational; also, itis known that Plant 4 was called "the pilot plant” affer Plant 6 was built
and before @ piiot plant was established at Plant 6, ‘Ttius, though it is unknown whether the listed
doses were received at Plant 1, Plant 2, Plant 4, or a combination of plants, the results likely reflect
doses received in the earfy operations prior to the improved control measures presumably
implemented in the construction of Plant 6. Further, fo what extent early “henchtop" operations may
have resulted in doses that differ from the estimates below is not known. Finally, as clear production
fevels have not come fo fight jor the early period, no allempt has been made to scale the exposures fo
Teifect the quantity of material processed. These factors resutt in dose estimates that are highly
uncertain, but represent the best information at hand.

‘The methodology used to create Table 36 was compared with the techniques discussed in Watson et
al. (1894). Whether it would be a better fit fo use the department median or mean, due fo the fact that
Mallinckrodt was a uranium facliify like Y-12, or to use the NEARBY procedure is unfortunately

academic in the case of workers without monitoring records subsequent fo the unmonifored period, as


lee / We have attached either documents or statemenis provided by affidavié that Indicate that

‘Special Exposure Cohort Petition U.S. Department of Health and Human Services

mpl by checking the appropriate box and providing
the required information related tw ihe sctcetion. You are not required to complete more than one entry.
Fi  aceton expoattes and raketn nec cements provided by adv that nda that
radiation exposures and radiation doses potentially incurred Taembers of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area
monitoring.

(itach documents and/or affidavits to the back of the petition form.) |
Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that potential radiation exposures were not monitored,

radiation monitoring records for members of the proposed class have been lost, falsified, or
destroyed; or that there is no information regarding moniforing, source, source term, or process

(Attach documents and/or affidavits to the back of tha petition form.)
Describe as completely as possible, to the extent it might be unclear, how the attached

documentation and/or affidavit(s) indicate that radiation monitoring records for members of the

proposed class have been lost, altered illegally, or destrayed.

rats

ka, 2 om )
 ceemmre en neyesenea aes
Part F is continued on the following page,

Name or Social Security Number of First Petitioner: _——


; AZ

[ Effective Date: 10/24/2008 _ | Revision No. 00 [Document No, ORAUT-TKES-0005 [Page 40 f 125" |

concentration. ‘The spiked samples and samples of the stock solution ware sent to Bames as reguiar
samples, while Bames standards and samples of the stock solution were sent to NYOO for analysis.
AEC also compared Bames methods and equipment. The conclusion was that the samples wore

1950)).

it is not clear whe did the urinalyses from 1950 fo 1954, although MCW (1950d) suggests that this
was no longer being done at Barnes Hospital but at AEC-NYOO. In 1954 AEC gave Mallinckrodt
permission fo perform their own urinalyses (MCW 1954), presumably in the laboratories at the .
Mallinckrodt St. Louis site. From the Mallinckrodt Health Office monthly reports, they ware analyzing

a year andthat urine.sampls that were taken were spit, with half going to AEC-NYOO for the
radiological analysis and half to Bames Hospital for the medical analysis.

Because of these questions regarding the validity of the samples and the variations in sample
analysis mettiods, the Mallinckrodt urinalysis data should be used with care. However, it appears that
the orrors, if any, are in the conservative direction and thus ara claimant-favorable.

Urinalysis records appear fo be available, but many appear to be handwritten notes on cards. These
are found scattered in various dose reconstruction project files. Fortunately, in about the 1970's, the
records were entered into a computer data base for research purposes and have been used in that
form since than by Oak Ridge Associated Universities and other research groups. The resulting file
has more than 40,000 records (Le., fines, with each lina representing one urinalysis). A"stripped"
version (ORAU 2003) is also avaliable, with the names and Social Security numbers removed for

privacy reasons.

‘The large stripped urinalysis file (ORAU 2003) was reviewed for comparable or surrogate worker
cases that could be used fo produce a table of intakes applicable when bioassay data for an Individual
is missing or spotty. ‘Cases were selected on the basis of their containing a reasonably

setias of urinalyses and having reasonably clear notations of job title and/or area worked In. The
selected cases were then further evaluated and a subset was extracted for each of various categories
of identified locations and operations or position files, These categories are given in Table 31. Where
there were more than two applicable cases for a category, the IMBA program was then used with the
assumptions of chronic intake and Type M form with the data from these cases to produce a category-
specific distribution and standard deviation for the typical daily intake, as shown in Table 31;
otherwise, the actual data (1e., for one or two cases) was given. Since there were changes m


we

.- ; Doc AZ
[Eifective Data: 1072472003 _| Revision No. 00 | Document No. ORAUT-1KBS-0005 | Paya dof 125 |

At the Oak Ridge Gaseous Diffusion Plant (ORGDP), test measurements In 1957 on clothing showed
that the highast spot reading was typically about 3.6 times the average reading (Becher #958}: this is
Labeled ta has oan Matiinckrodt as well, although the uranium compounds at ORGDP were
whereas the Mallinckrodt compounds were insoluble. The ORGDP tests also
show 1620 deh pea be oqeet S700 com as measured on @ Samson aipha
an “efficiency-geometry” factor of 6%. {Note that for the “surface transferable activity"
on files paper used for ar sorpling Lice reporied in Bacher 1808, an ofieioney-quommsty factor of
20% was assumed for the Samson alpha meter.) Finally, the ORGDP measurements showed that
about half the uranium applied to the clothing at the beginning of the test had dropped off within the
first two hours of wearing.” This suggests that uranium that gets on clothing can come back off it
readily and that surface cortammation on clothing can contribute to airbome levels via resuspension.

Railcar inteslors were invariably found to be contaminated above 2500 dpnv'100 cm? after unloading
uranium oxide, UF,, or urankim metal at uranium processing plants, even though the sites made an
effort to decontaminats them (AEC 1949). AEC advised that sirippable coatings would eventually
need to be used (AEC 1949), but there was no evidence that this was ever done. This suggests that
even where closed containers of uranium-bearing materials were being unloaded, i must be assumed
that surface contamination was typically present.

5.3.6

processing @ pre-employment

inkial urivalyis env! toto one ca thoy wees given St ented oheokot fret inlatod a routing
urinalysis and a blood count (MCW 1955; Mason 1958a). From about the summer of 1948 on, this
included a measurement of uranium in the urine. In addition, up to March 1954 some worker
Glassifications had more frequent urinalyses, either every 4 months or every 6 months depending on

the workerclassification (MCW 1955; Mason 1958a); after this; timé the Irequency was no more than
semiannual (MCW 1955). As urinalysis records indicate, some office workers appear to have been
Sivan urinelyses, but it ie not cleer whetho+ thie was done on a regular base.

radi pe / only for iranlurn content (refered to 2s "X In urine” or

clear' the urinalyses were done, but Ross et al: (1975) states that for
all AEC contractors before 1961, estimates of lung dese were made on the basis of urinalysis and that
this was usually done on the basis of electrodaposition and subsequent counting.

The urinalyses were performed by AEC-NYOO from about 1948, when Bames Hospital at
Washingign University (St Laula} bogan to do from, However, an AEC health official stated (AEC
1948) that it was his understanding that the analyses were being done at Bames Hospital (at
Washington University), but it tumed out that they were being done in faboratories at the Mallinckrodt
St ponders This came to light when it was discovered, apparently in late 1947, that some urinalysis
were contaminated due fo contamination in the laboratory. An undated, untitied urinalysis
isting found in doce TecemsluchGn eal Ta eel ee a blank samples were found to
have significant levels of uranium in them, indicating contamination in the laboratory; was suggested
that this might explain the high levels of some of the non-blank (worker) samples. Thus at least the
early urinalysis samples must be considered to be potentially contaminated (1.e., some of the uranium
content may have come from the faboratory analyzing them).

Apparently Bames Hospital resumed doing the urinalyses (MCW 1950b). However, in 1949, AEC
the Mallinckrodt analyses against those for other sites handling similar material and

conctuded that the results were consistently high {MCW 1950b). They then sent Mallinckrodt some

spiked samples and aiso had an independent Mallinckrodt party prepare a stock solution of known



Mallinckrodt workers 1942-1967, to the Special Exposure Cohort.

® yectly shied


”  [ Eiisclive Date: 10B08008 | Revision No, 00 | Documant No. ORADTARBS0008 [Page ar 25]

individual doses, except possibly for those individuals actually counted. However, even individual
whole body and lung count data appear to be unavailable

5A EXTERNAL. DOSE CONSIDERATIONS

Extemal doses for Malfinckrodt workers varied widely widely depending upon the actvily Hey perrammed.
Operations at the refinery (Plant 6) involved primarily gamma radiation, while operations at the metal
plants (Le., Plant 4 and later SE) entailed primarily beta radiation (AEC 1949).

There is little information about conditions in Plants 1 and 2 during the waitime startup: no dose rate

by film badge
at Plants 1 and 2, for the same type of work, were not greatly different from those at Plant 4 and Plant
6 around 1948.

According fo MCW (1955), at lesst late in the le of the site, gamma surveys ware done bimonthly in
areas and monthly at the vent ducts in the digest area. However, these
raoores dolack appnarts be available.

measures in plants and equipment resulted in low doses In Plants 6& and 7 compared with the mixed
beta-gamma doses in the refinery operations.

The gamma dose fate could be as high as 50 mfVhr near stacks of drums of Belgian Congo ore at
25% concentration and with a radium content of about 100 mg/ton (Etsenbud 1975). Dose rates at
points adjacent to stacks of drums of radium-bearing residues (precipitates) could run as high as 100
mFUhr adjacent to stack of drums (~ 300 mg Rafton} (Efsenbud 1975, Table 2). In addition, a 1958
AEC report on uraniuni mills gave dose rates of 0.8 to 8.0 mF¥hr, with an average of 3.0 mFhhr, as the
garama dose rate at three feet from bulk ore concentrates (AEC 1958, Table XI); these dose rates are
assumed to be for domestic ores. AEC (1948) gave the gamma contact dose rate with the (Ra-
containing) Feins filtrate sludge under equilibrium conditions as. over 300 mFvhr, however, they stated,
they had no way of knowing how close to equilibrium it was.

Some more specific information regarding gamma dases in the ora, refinery, and metal processing
areas are shown in Tables 33-35. Dose rates from drums and railcars are shown in Table 33; from ore
storage in Table 34, for Middlesex workers (¢ (comparable to ore storage areas at Mallinckrodt); and for
various Plant 6 focations in Table 35, pasticularly for GLC (gangue fead cake or K-65, the radium-
containing residue). It should be noted that operations that were particularly manual were the various


Special Exposure
Cohort Petition
Submitted on behalf of the Mallinckrodt employees

United Nuclear
Weapons Workers
N St. Louis Region


JR OBS Ah

» £4fes by: » Nene, or 2) film number, or 3) payroll mmber~—but never

‘by Social Seeurity number, wrich is, of course, required by CHC to
identify wita a person. . .

First priority was assigned to complete the prograa a planning so as
to instruct the key punch representative from University of Pittsburgh,
who is to be here on or about August 188, .

Now, concerning the 39 names identified as Non Exposed, the. follow-
ing judgwents were submitted by M. Hason: oo, .

1. Many of these were Main Plant guards who were never assigned
to guard duty at Plant 4 or Destrehan or Plant 51 or Weldon Springs.
It was postulated that these names were picked up at M0w head-
quarters by University of Pittsburgh investigators: in 1967 when
they went there to search out additional nanes of possibly exposed
uraniun project employees fron sources not in the Uranium Health
files... The investigators. had no | way of mowing how to sort out--
candidates from non-candi¢ates. The clerks who provided them with
raw personnel or payroll files were eager to supply more than
enough records and so gave the investigators files of people who
might have been associated with the project. Many Plant 1 guards |
who were not project workers fell in that category. The sane is
true for many employees in various administrative service groups
at the Main Plant who received some pay fron project accounts but
never went near. the uranium areas. I suspect that there nay be as
many as 300 non project esployees or consultants in tris eatesory.

More dependable means are being sought to test for and identi-
fy those individuals as being non project for purscoses of the data
bases,

The denlti: ic Safety department persomiel reportedly searched

all corporate files in 1998-19:9 for the nene and stork history of


enemuen hye

sistas Jobe ssa o owe oheitiga2 Zeberas S



ar]

. * |Special Exposure Cohort Petition : U.S. Department of Health and Human Services} =~
~ ‘Junder the Energy Eraployese Cocupational + = Centers’

for Disease Control and Prevention
Miness Compensation ; Nalionat inetilute for Occupational Safely and Health
“- - > OMB Number: 0920-0639" Expires: 05/31/2007; .
- |Special Exposure Cohort Petition — Form B . : Appendix — Continuation Page |
ROT: y

— : 4 n
Or tre-U.5. Governments MED 4A
¥2d WErkars Ino IGF3— |asy
, OIROCS PO [ie

1 (Q) z z

STAUNES Ce Taare of Uranium

est aor

eurensaee

Attach to Form B if necessary.

p Name or Social Security Number of First Petitioner:



‘y 4] Special Exposure Cohort Petition “US Bopartment of Health and Human Services
. under the Energy Employees Occupalional Ceniers for Disease Control and Prevention
Miness Compensation Act .

Attach to Form B if necessary.

Fd Name or Sociat Security Number of First Petitioner:


“ 53) MALLINOKACD? CHITA. ‘oams' —— .D CAD

Subject: Concerning the Grouping of Death Certificate Cards into

Exposed VS unexposed groups. 2 | .
The exposure printout cards are incorrect in tuo major aspects: |
1. Under the headings: Internal Exposures, External Exposures, .
Breath Redon Exposures: =000 is used whare there’ is no record of
exposure. This, of course, is incorrect. begduse *£-Leaves an.in-

pression that tests were made with zero results. . Whereas, in many

cases, there were no tests made (or recorded as yet-in- the cfc .
files) so the magnitude of exposure is nat know. _ The apuropriate
printout would be “No Data" where that is appropriate. The record
-000 should appear only where test results. are recorded as zeros
Note: When .000 is printed below the subhead Internal Exposure
and there were no entries for the individual; a «000 when acconpa—
nied by a date- denotes. a negative. finding, ieee, No Exposure; this
is an erroneous conclusion.

2. It is wy opinion that the nost severe and important exposures
before 1948 were to radioactive dust. Dust exposure velues Bsve
not yet been entered into the O20 files. Urinalysis for uraxiun
was not begun until 1948. Urinary uranium results have been coded

into the CTC files as Internal Exposures. I have consistently ob—
dected to tais as a misleading terminology waich should be changed.

to read just what it is: . vranium in urine. A positive UU value
of course specifically identifies witha internal deposition of ura-
nium by sone mode of entry but does not identify vith any know
magnitude of internal deposition or dose. We hove eventually to
attach some exposure sienificence to UW values.

A zero JU (internal exposure) value rould suggest minimal dust

exposure during the period preceding the ceiving of 2 urine sanle.


Q Or Wy : Ae

‘ ae veers former and the then current uranium project esployees,
a

+

2009 in
that there

Phese were recorded and poten job history ané a dust exposure in-
dex for each of those individuals ves constructed, except that
they aia not construct the exposure index for guards, some former
aduinistrative employees, and some vers short term employees.
However, they did record, file, and preserve the names collected
and confirved as having been nroject employees. ,

Et was reconnendéd that the nanes and dust exposure histories
referred to above be accepted as the only vona fide List of Hallin~
ckrodt Projeet employees prior to 10/1/49 and that additions to or
deletions from those name lists be permitted only ‘when there.is
compelling evidence to do so. It was further recommended that the
present C7C files remain intact along with the complete data sheet

file; however, any nate which dees not appear in a Health Depart-

ment file’ should’ be clearly identified asa non project person wio
cannot be included in the. Health and Mortality evaluation unless
there is a specific need and justification to do so for any one or

all of the individuais.

column at ené of all entries merely reflects the fact
vere no entries in this column (no exposure data recorded).